Does the QI report my exchange to the IRS?

The 1099-S comes from whoever closed the sale, not from the intermediary

The Form 1099-S instructions put the filing duty on 'the person responsible for closing the transaction', and where a Closing Disclosure or other settlement statement is used, that is the person listed on it as settlement agent. In most sales that is the title or escrow company, or the closing attorney. The rules behind this sit in Reg. Section 1.6045-4.

An exchange does not switch the form off. The instructions say a sale or exchange includes any transaction treated as a sale or exchange for federal tax purposes 'even if the transaction is not currently taxable'. So the settlement agent reports your gross proceeds in box 2a under your name and taxpayer identification number, while the cash itself goes to the intermediary.

How the boxes are filled for an exchange, including the box that flags property received, is covered in Form 1099-S and the 1031 exchange. The point here is narrower: the form is not the intermediary's, and nothing on it tells the IRS an exchange happened.

Form 8824 is the only filing that tells the IRS your sale was an exchange

The Instructions for Form 8824 are direct: if during the tax year you transferred property in a like-kind exchange, 'you must file Form 8824 with your tax return for that year.' That is your filing, prepared by you or your preparer, and it is the document that reconciles the gross proceeds on the 1099-S with the gain you deferred.

Form 8824 also carries the parts of the exchange the intermediary knows about but never reports: cash you received, net debt relief and exchange expenses on line 15, and the basis carried into the replacement property on line 18. For a related-party exchange, the same instructions require Form 8824 for the 2 years following the exchange year as well.

A step-by-step walk through the lines is in how to fill out Form 8824. If you bought several replacements or trust interests, read Form 8824 with multiple properties before your preparer starts.

The intermediary's only information return is for interest, and only if the earnings are yours

Reg. Section 1.468B-6 starts from the assumption that exchange funds are loaned from you to the exchange facilitator, which then takes the earnings into its own income. If the agreement instead pays all the earnings attributable to your funds to you, you report them, and paragraph (d) of that regulation requires the payor to file information returns on that income to the extent the general reporting rules require.

In practice that means a form reporting interest under your name, not a form describing the exchange. Whether you earn anything at all depends on the agreement, which is covered in interest on exchange funds.

Some states add their own reporting through the intermediary. California, for example, places withholding on boot with the intermediary; the state forms involved are covered in state withholding at closing.

A hypothetical: what the IRS sees from a $900,000 exchange

Hypothetical figures: you sell a rental for $900,000 in March 2026, the buyer's money goes to your intermediary, and in August you buy a $1,000,000 replacement. The settlement agent files a 1099-S showing $900,000 in box 2a. The intermediary files nothing about the exchange, and if your agreement paid you, say, $4,000 of interest, it reports that $4,000 as interest.

Early in 2027 the IRS holds a $900,000 sale under your number. Your 2026 return answers it with Form 8824 showing the relinquished and replacement properties, the dates, and zero recognized gain. Without that form, the matching program sees a large sale with no reported gain, and the follow-up letter is described in the 1099-S page. Run your own numbers with your CPA.

What to collect from the intermediary so your preparer can file

Because the intermediary does not report the exchange, the burden of documentation is yours. Ask for the executed exchange agreement, the assignment notices, your identification notice with its date, the settlement statements for both closings, and an accounting of every dollar in and out of the exchange account, including fees and any earnings.

Those papers are what your preparer needs for the dates in Part I of Form 8824, including the identification date on line 5, and for the boot and basis math, and they are what you would produce in an examination. The retention side is in records to keep after a 1031.

If your replacement is a Delaware Statutory Trust interest, the trust's sponsor sends its own annual tax reporting, which is separate from the exchange reporting described here.